EBF draft response to the BCBS
consultation on internal models

Publication date: 24 June 2016

The EBF welcomes this opportunity to participate in the international debate on the use of internal rating based (IRB) models for regulatory purposes. The European banking industry has always shown continued commitment to the development of harmonised regulatory standards that pursue financial stability and, at the same time, respect banking business and risk management practices, including the use of advanced models. European banks collaborated with the Basel Committee and their supervisors in the definition and adoption of the Basel II Accord as a global standard for capital adequacy overcoming the limitations of the previous standard of Basel I.

This EBF response paper is organised in three parts:

– Key points, in general and in particular;
– General remarks;
– Specific comments in the order of the consultative paper.